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Reassessment Cannot Be Based Solely on DVO Report: Delhi High Court Quashes Section 148 Notices in Divine Infracon Pvt. Ltd. v. DCIT (2024)
Facts
of the CaseDivine
Infracon Private Limited, the petitioner, is engaged in the business of real
estate development and hospitality. A search and seizure operation under Section
132(1) of the Income-tax Act was c...
Reassessment Notices Issued Post Abhisar Buildwell Barred by Limitation: Delhi High Court Quashes Section 148 Proceedings in Dharampal Satyapal Ltd. v. DCIT (2024)
Facts
of the CaseDharampal
Satyapal Ltd. (DSL), the petitioner, is the successor entity of Abhisar
Buildwell Pvt. Ltd. (ABPL) pursuant to a court-approved scheme of arrangement.
ABPL had been subjected to a search an...
Disallowance of WIP Out of Disclosed On-Money Not Sustainable – Section 40A(3) Cannot Lead to Double Taxation; Unsecured Loan Through Banking Channel Not Taxable u/s 68 | Shanti Developers v. DCIT (ITAT Rajkot)
Shanti
Developers v. Deputy Commissioner of Income-tax ITA Nos.
827/RJT/2024 & 274/RJT/2025 (AY 2011–12)ITAT Rajkot
BenchDecision dated:
28 January 2026Coram: Dr.
Arjun Lal Saini (AM) & Dinesh Mohan S...
Interest Under Section 234B Payable Only up to Admission of Settlement Application: Delhi High Court Upholds Brij Lal Principle in CIT (Central)-III v. Income Tax Settlement Commission (2024)
Facts
of the CaseA
search and seizure operation under Section 132 of the Income-tax Act, 1961 was
conducted in the Radico Khaitan Group, in which the respondent-assessee, Dalip
Kumar Banthiya, was the Chief Financial...
Assessment and Reassessment in the Name of Amalgamating Company Held Void Ab Initio: Delhi High Court Applies Maruti Suzuki Doctrine in BSBK Engineers Pvt. Ltd. v. ACIT (2024)
Facts
of the CaseBSBK
Engineers Private Limited is the resulting company pursuant to a
court-approved Scheme of Amalgamation under which Parishudh Finance Company
Pvt. Ltd., the amalgamating company, stood merged and...
Assessment and Reassessment Against Amalgamating Companies Are Jurisdictionally Invalid: Delhi High Court Reaffirms Maruti Suzuki Principle in BSBK Engineers Pvt. Ltd. v. ACIT (2024)
Facts
of the CaseBSBK
Engineers Private Limited is the resulting company pursuant to a
court-approved Scheme of Amalgamation under which Parishudh Finance Company
Pvt. Ltd., the amalgamating company, stood merged and...
Reassessment Notices Barred by Limitation After Abhisar Buildwell: Delhi High Court Quashes Section 148 Proceedings in Bhadani Financers Pvt. Ltd. v. ACIT (2024)
Facts
of the CaseThe
petitioner, Bhadani Financers Pvt. Ltd., was subjected to reassessment
proceedings through issuance of a notice under Section 148 in November 2023
for a completed/unabated assessment year.Earlier...
Reassessment Notices Invalid Without Proper Sanction Under Section 151: Delhi High Court Quashes Section 148 Proceedings in Atma Ram Singhania v. ACIT (2024)
Facts
of the CaseThe
petitioner, Atma Ram Singhania, along with other connected assessees,
challenged reassessment proceedings initiated for Assessment Year 2015-16
through notices issued under Section 148 of the Inc...
Delhi High Court Reaffirms Mandatory Nature of Draft Assessment Order Under Section 144C – AT Kearney India Pvt. Ltd. v. DCIT (2024)
Facts
of the CaseAT
Kearney India Private Limited (“the Petitioner”) was subjected to assessment
proceedings involving transfer pricing adjustments. The Transfer Pricing
Officer (TPO) passed an order proposing ad...
Reassessment Notices Barred by Limitation Post Abhisar Buildwell: Delhi High Court Quashes Section 148 Proceedings in ARN Infrastructures India Ltd. v. ACIT
Facts
of the CaseThe
petitioner, ARN Infrastructures India Limited, challenged multiple
reassessment proceedings initiated for various assessment years by issuance of
notices under Section 148 in November 2023 and Ma...